Document a118bnyoxooRnmJgzKzy44R3b

814. If any employee or ottier of defendant hat testified at trial or by deposition an any litigaticr, involving ar.y allayed occupational exposure to asbestos, state: ANSWER: Non*. (I Kane, addraaa and title of each such pereon who testified; (b) Date, location and forit of testimony; lc) Whether defendant ha* a copy of *uch testimony. 8JS. Ha* defendant at any tire since its inception, maintained any office or department dealing with medical research? If so, state: ANSWER: No. (a) The name of each such department; (b) The dates each such department was in operation; |c> The name, address and Job position of each such person who has been in charge of said department or departments. B3(. When was the first time the defendant became aware of or knowledgeable of any disease or illness associated with or causally related to the inhalation of asbestos, asbestos fibers or asbestos dust in any forsi whatsoever? Indicate which disease defendant beeane aware of and describe how defendant became aware of its alleged relationship to inhalation or exposure to asbestos. ANSWER; In the 1930's Chrysler recognised that raw asbestos fiber inhalation in large quantities could cause or contribute to pulmonary disease. S37. In reference to the preceding interrogatory, if defendant acknowledges a causal relationship between asbestos and dlssase or illness, set forth the following information: ANswat Chrysler Motors Corporation does not acknowledge a causal relationship between exposure to brake dust and disease or illness. (a) What diseases or illnesses defendant acknowledges are causally related to or associated with exposure to asbestos dust or fibers; (bl The date upon which defendant became aware of the association with or causal relation to each such disease or illness; Me) The date upon which defendant confirmed the causal relation of each such disease to exposure to isbestos dust or fibers; fd] How defendant became eware of each such causal relationship or association, indicating the source of all such information. -9 -